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New Canada/Hong Kong Double Tax Agreement: Comments on Selected Aspects

The new Canada/Hong Kong Double Tax Agreement (the “Agreement”) came into force on 1 January 2014. The implications for both Canadian and Hong Kong persons are significant, as this article will show. The Agreement follows the standard OECD international tax treaty model in most respects, which is perhaps surprising because the tax systems of the Parties are so different. Hong Kong has a territorial tax system, while Canada levies tax on world income.